opposing unnecessary, excessiveand intrusive powerline development

REVOLT Newsletter 3

1. David Kirkland, the KEMA project manager for the undergrounding report (news314, 315) has responded to Revolt’s contact and assured us that our submission will be considered. He says “we intend to have the report available for public access, via the IET website, in early February”.

2. There appears to be some difference of perception of the openness, or not, of the KEMA review. On the one hand a National Grid spokesperson on the contact line for NG’s related consultation said “it is not an open review”, but “is an expert review” for “technical information”. On the other hand, David Kirkland is surprised at such a description and explains the openness of the process.

3. David Kirkland says "A key part of the data gathering exercise has been a stakeholder engagement initiative where we have consulted with 49 different stakeholders including transmission operators, lobbyists, industry participants and local groups objecting to transmission developments. Part of this process was a stakeholder day that was held at the IET in London on 9th December 2010 when we heard 8 different presentations on the impacts of overhead lines and alternatives." A list of the 49 different stakeholders has been requested but not yet supplied.

4. KEMA initiated the project on 12th November along with a press release (still available on the IET website) announcing the KEMA and IET study in which all interested parties were invited to submit evidence. The leading public interest groups for powerlines were not informed and were unaware of this. No deadline was given and the contact for submitting responses was only a phone number. When I phoned it in the week before Christmas the relevant people were on holiday. I was given a personal mobile but did not use it as the person was on holiday.

5. We commend the stakeholder engagement initiative, as far as it goes, but it appears to be surprisingly limited in scope and time. Time is of the essence. The announcement that a review was to be commissioned by NG was made with the government response to the draft NPS (news310.6) but details and time scale were not then available. The “stakeholder day” on 9th December omitted the key England and UK public stakeholders, who were unaware of it. In practice and in effect it seems like a closed day for limited invited stakeholders only. With the report expected to be completed in January and public in early February, it is now dangerously late for new material and ideas to be given proper consideration, and already too late for the omitted (voluntary) groups to be able to provide direct and optimum input. KEMA say (7th Jan) “We are not really in a position to accept significant new information at this time”.

6. The KEMA review did engage with CPRE / CNP / AOAONB, who made a joint submission, but these are general countryside bodies not specialists in powerlines, and naturally their submission is limited and omitted some of the most important recent sources (news315). KEMA also engaged with “Suffolk Amenity Group” and “No Moor Pylons”, the Suffolk and Somerset groups opposing the two main local powerline proposals currently before IPC. But the KEMA review did not engage with the leading England-based UK specialist groups (Powerwatch and Revolt) which have represented the public interest regarding powerlines for the last 20 years or more, and nor did it engage with the Scottish and Irish groups who are key UK stakeholders.

7. Stirling Before Pylons (SBP) and other Scottish public groups acted together in responding to the Beauly-Denny proposal. They “only heard about the KEMA study from the Somerset group after their Dec 9th presentation”. SBP said “Just before Xmas we were hastily invited to make a written submission to KEMA bearing in mind the Jan 21st publication date. This was at the behest of the Scottish Government who clearly only became aware of KEMA at the beginning of Dec, and then had a presentation from KEMA in mid Dec.” Safe Electricity in Armagh and Tyrone (SEAT) led public responses to the Irish interconnector proposal in Northern Ireland. They had not been contacted about the KEMA review. While the Scottish and Irish proposals fall outside IPC, the technical reports and rebuttals connected with them will surely be referred to in future IPC cases, including the Suffolk and Somerset proposals at the application stage. The KEMA review will need to address the issues and disagreements involved, especially the Europacables and Askon rebuttal reports.

8. It is important and appropriate that KEMA should have engaged the new groups in Suffolk and Somerset, not least as they are opposing projects currently before IPC. The terms of reference of the KEMA review do refer to the two current proposals in Suffolk and Somerset but also, sensibly, seek “to establish an authoritative view of cost of undergrounding and subsea cabling” in order to “avoid time being wasted at IPC hearings dealing with this issue”. Restriction of specialist public stakeholder engagement exclusively to two new and relatively inexperienced groups in Suffolk and Somerset is unreasonable, especially since the omitted leading national groups have made the running on comparative costs for undergrounding through their own commissioned expert professional reports, through their submissions to public inquiries, and through their work with NG and government departments in the SAGE group. KEMA has assumed, wrongly, that the other more experienced public groups would have “a similar viewpoint” to the new groups (“Suffolk Amenity Group” and “No Moor Pylons”) and therefore no others needed to be engaged. That has led to serious omissions in the technical reference sources considered, especially with regard to professional rebuttals of reports commissioned by governments and developers. The KEMA review really should examine the rebuttals as carefully as the original government and industry reports; otherwise it will neither have the confidence of stakeholders nor serve the terms of reference as quoted above.

9. The terms of reference for the KEMA review include highlighting practical considerations and noting typical environmental impacts. This can be a very wide area which cannot adequately be treated in such a limited study. The more useful point of the study will be to assess costs. That may help to avoid repetitive debate before IPC. But environmental impact and practicality issues can run into political policy issues. It may be worth listing what other EU countries do by way of policy and practice, but it may also be helpful for the report to acknowledge that a balanced account of impacts such as on property values, health and amenity would require a further study. The CPRE submission also says that a further study is needed into such things as amenity benefits of undergrounding.

10. The Yorkshire 400kV line (oil-filled cables, 2001) is sometimes (e.g. EC Background Paper 2003) cited as an example of negative environmental impact of UGC with the description of a “15-30 metre swathe of sterilised land through the countryside”. This has been used in adversarial proceedings to misrepresent the real impact of UGC as if it were long term. While there is a minor and immaterial longer-term restriction on land use (planting deep rooted trees), in fact there is no “sterilised swathe through the countryside” at all in Yorkshire. Crops are grown normally over the cables, the presence of which is not normally visually detectable. The terms of reference restrict the KEMA review to desk research, so a site visit or talk with landowners may not be possible, but there are photographs and comments at www.revolt.co.uk . The environmental impact of UGC has been exaggerated in adversarial public hearings and the exaggerated impressions have been picked up and reflected in official reports such as the EC Background Report and the ICF report 2002. KEMA should not repeat and continue this error.

Statements made by the editor or by other parties and quoted for information do not necessarily represent the views of Revolt. Criticism of government and industry, and grievances from members of the public, are in the nature of Revolt's work, though we try to give credit where it is due. Revolt is strictly non-party-political and regrets any offence which may be inadvertently caused.